Keep in mind regardless of a general statement from a supplier vendor or manufacturer you will still need a copy of any non-exempt raw material's GCCs with the lead content stated in PPMs and the test results must be from an a pre-approved 3rd party lab. This is according to an update on the stay of 3rd party testing
http://www.cpsc.gov/cpscpub/prerel/prhtml10/10083.html .
"Component Testing Adds Flexibility to Compliance
Significant to domestic manufacturers, crafters and U.S. importers, the Commission has also voted unanimously (5-0) to adopt an interim enforcement policy allowing component part testing. Under this policy, domestic manufacturers and importers now have a choice in certifying their products. As before, they can send samples of the entire children’s product out for independent third party testing. Now they can certify their products as meeting lead paint and lead content limits in the following ways:
Lead in Paint
Have test reports from recognized independent third party testing labs showing that each paint on the product complies with the 90 ppm lead paint limit.
OR
Have certificates from paint suppliers declaring that all their paint on the product complies with the 90 ppm lead limit based on testing by recognized independent third party testing laboratories.
Lead content
Have test reports from recognized independent third-party testing labs showing that each of the accessible component parts on the product complies with the 300 ppm lead limit.
OR
Have certificates from part suppliers declaring that all accessible component parts on the product comply with the 300 ppm lead limit based on testing by recognized independent third party testing laboratories.
Most fasteners, such as buttons, zippers, and screws, sold by themselves are not considered children’s products and would not have to comply with the lead limits or be certified. However, the same fasteners must meet the lead limits if they are used on a children’s product. Voluntary certification by suppliers of component parts would make them more beneficial to manufacturers who use them in children’s products.
Any person who issues a false certificate is subject to penalties.
CPSC is working to provide manufacturers and importers with clarity on the Consumer Product Safety Improvement Act (CPSIA) and their responsibilities to comply with the law. The agency intends to implement the law in a firm but fair manner in order to build consumer confidence, keep children safe and keep businesses open and competitive.
While the stay of enforcement remains in effect for the certification and testing requirements for certain products, all products must comply with the safety standards and bans of the law, including the limits for lead content, lead paint, the ban on certain phthalates and the ASTM F-963 mandatory toy standard."
